Summary Under the proposed Cloud and AI Development Act (CADA), Croatia would be required to designate one or more Single Information Points (SIPs) to assist data centre operators with all authorisations for projects within designated data centre acceleration zones. These SIPs would coordinate the entire permitting lifecycle, potentially upgrading existing points established under the Gigabit Infrastructure Act (Regulation (EU) 2024/1309). Crucially, CADA would mandate that Croatia issue an aggregated baseline permit for each acceleration zone, covering zone-level authorisations (such as spatial planning and environmental assessments) while excluding installation-specific permits. This framework aims to cap the remaining permit-granting procedure for individual projects at 12 months, significantly reducing administrative fragmentation and accelerating deployment timelines for cloud infrastructure in Croatia.

Detail

The proposed Cloud and AI Development Act (CADA), COM(2026) 502 final, introduces a harmonised regulatory framework designed to address the critical bottlenecks in data centre deployment across the European Union. For Member States like Croatia, the proposal imposes specific, binding obligations regarding the designation of administrative support structures and the issuance of zone-level permits. These measures are intended to reduce regulatory fragmentation, ensure legal certainty for investors, and facilitate the rapid deployment of computing capacity within designated acceleration zones.

Single Information Points (SIPs) under Article 12

Article 12 of the CADA proposal establishes a mandatory obligation for Member States to designate Single Information Points (SIPs) specifically to support data centre operators. The provision explicitly grants a right to the operator, stating: "The data centre operator shall have the right, upon request, to be assisted by a single information point throughout the entire lifecycle of the data centre project in an acceleration zone with respect to all authorisations required for the deployment of the data centre."

This assistance is not discretionary for the authorities; it is a statutory right of the operator. The SIP's role is comprehensive, covering the "entire lifecycle" of the project, from initial planning and construction to operational phases where specific authorisations are required. Article 12(2) details the specific functions of the SIP, which include coordinating, facilitating, monitoring, and sharing information on procedures relating to:

  • Spatial planning and building permits;
  • Environmental assessments (in accordance with the proposed Regulation on speeding-up environmental assessments);
  • Authorisations regarding water abstraction, wastewater discharge, and heat utilisation and recovery;
  • Compliance with applicable administrative and reporting obligations;
  • Information to the public, with the aim of increasing public acceptance of the data centre project;
  • Applications for connection to electricity, heat, or communications networks.

A key feature of Article 12 is its flexibility regarding administrative integration. To avoid the creation of redundant bureaucratic layers, CADA explicitly allows Member States to leverage existing infrastructure. Article 12(1) states: "The Member States may designate for this purpose a single information point established under Regulation (EU) 2024/1309." Regulation (EU) 2024/1309, known as the Gigabit Infrastructure Act, already mandates SIPs for the deployment of gigabit electronic communications networks.

For Croatia, this provision offers a clear pathway to compliance. The country could designate its existing Gigabit Infrastructure Act SIPs to also serve data centre projects. If Croatia chooses this route, the functions, procedures, and mechanisms applicable to the Gigabit SIPsβ€”including digital access, administrative coordination, and dispute settlementβ€”would automatically extend to data centre projects. This integration ensures that operators can engage with a single entry point for both connectivity infrastructure and data centre deployment issues, streamlining the interaction with national and local authorities.

Furthermore, Article 12(3) assigns a strategic advisory role to the SIP: it "shall assist in assessing whether a data centre project may qualify as a strategic project under Article 14." This guidance is vital for operators seeking the additional support measures and streamlined procedures associated with a strategic designation. To ensure inclusivity, Article 12(4) requires SIPs to pay particular attention to small and medium-sized enterprises (SMEs). Member States must ensure that SIPs establish dedicated communication channels to provide guidance and respond to queries from SMEs, recognising that smaller operators may lack the internal legal and administrative resources to navigate complex cross-departmental permitting processes.

Aggregated Baseline Permits under Article 13

While the SIP facilitates the administrative process, Article 13 fundamentally alters the nature of the permits themselves for projects located in data centre acceleration zones. The core mechanism introduced is the aggregated baseline permit. Article 13(2) mandates: "For each designated acceleration zone, Member States shall prepare and issue an aggregated baseline permit authorising the deployment of data centres in that acceleration zone."

This permit is a zone-level instrument, distinct from traditional project-specific permits. It covers the permits and administrative authorisations commonly required for data centre projects within that specific zone, explicitly excluding installation-specific permits. Before issuing this baseline permit, Member States must carry out all necessary procedures and assessments at the zone level. Article 13(3) requires that "Member States shall carry out all necessary procedures and assessments, including any relevant environmental assessments, planning procedures and evaluations applicable at the level of the acceleration zone."

The practical impact for operators in Croatia would be significant. Article 13(4) clarifies the scope of this reform: "Data centres deployed in acceleration zones shall be required to obtain additional permits only for activities falling outside the aggregated baseline permit." This means that once the baseline permit is in place for a zone, an operator deploying a data centre there is exempt from re-litigating zone-level issuesβ€”such as general environmental impact assessments or spatial planning compatibilityβ€”that have already been assessed and approved for the zone. The operator only needs to secure permits for elements unique to their specific installation that were not covered by the baseline.

Article 13(5) introduces a strict timeline for the remaining administrative burden. It states: "The permit-granting procedure for data centre projects deployed in data centre acceleration zones shall not exceed 12 months, from the moment a comprehensive application has been submitted." This 12-month cap applies specifically to the remaining installation-specific permits. Additionally, the article provides that where national law already provides for a status of "highest national significance," data centre projects must be allocated that status and treated accordingly in permit-granting processes. However, CADA does not obligate Member States to introduce such a status if it does not already exist in national law.

Interaction with Croatian National Frameworks

For Croatia, the implementation of CADA would require aligning national spatial planning, environmental assessment, and building permit laws with these EU-level mandates. The designation of acceleration zones (under Article 10) must consider factors such as grid capacity, network connectivity, and environmental sustainability. The SIPs and aggregated baseline permits must be integrated into Croatia's existing administrative structures, likely involving the Ministry of Regional Development and Funds or relevant digital infrastructure bodies.

The ability to use the Gigabit Infrastructure Act SIPs suggests that Croatia may already possess the structural foundation to meet CADA's requirements. By upgrading the mandate of existing SIPs rather than creating entirely new entities, Croatia could minimise bureaucratic overhead while maximising operational efficiency. The aggregated baseline permit would require a shift in how environmental and spatial assessments are conducted, moving from a project-by-project basis to a zone-wide strategic assessment, which aligns with broader EU goals of accelerating green and digital transitions.

What this means for you

For CTOs, infrastructure architects, and SMEs evaluating data centre investments in Croatia, CADA's provisions on SIPs and baseline permits offer a pathway to reduced uncertainty and faster time-to-market, provided the investment is located within a designated acceleration zone.

  • Single Point of Contact: You would no longer need to navigate a fragmented landscape of separate municipal, environmental, and utility authorities independently. By engaging the designated SIP, you gain a coordinated guide for all authorisations. This is particularly valuable for SMEs, which may lack the dedicated legal teams to manage complex cross-departmental permitting processes.
  • Predictable Timelines: The 12-month cap on permit-granting procedures for installation-specific permits provides a clear, legally binding deadline for regulatory approval. This allows for more accurate project scheduling, financial modelling, and risk assessment.
  • Reduced Redundancy: The aggregated baseline permit means you would not need to repeat environmental or spatial planning assessments that have already been completed for the zone. This reduces both the time and cost associated with the initial phases of deployment, as the "zone-level" risks are already mitigated.
  • Strategic Project Assessment: The SIP can assist you in determining if your project qualifies as a strategic project under Article 14. Strategic projects may benefit from additional support measures, including potential state aid (subject to EU rules) and further streamlined procedures.
  • SME Support: If you are an SME, you should actively seek out the dedicated communication channels that SIPs are required to establish. This can provide tailored guidance on navigating the regulatory landscape and accessing specific support mechanisms.

Common misconceptions

"The SIP approves the project." No. The SIP does not have the authority to grant or deny permits. Its role is strictly to assist, coordinate, and facilitate the process. The actual authorisations are still issued by the relevant competent authorities (e.g., environmental agencies, building inspectorates). The SIP acts as a navigator, not the decision-maker.

"No permits are needed in acceleration zones." This is incorrect. An aggregated baseline permit covers zone-level authorisations, but operators still need to obtain installation-specific permits for elements not covered by the baseline (e.g., specific building details, unique technical configurations). The process is streamlined, not eliminated.

"CADA creates entirely new SIPs." CADA explicitly allows Member States to designate existing SIPs, such as those established under the Gigabit Infrastructure Act (Regulation (EU) 2024/1309). Croatia is expected to leverage its current digital infrastructure administrative bodies rather than creating new ones from scratch, ensuring continuity and efficiency.

"The 12-month timeline applies to the entire process." The 12-month limit applies specifically to the permit-granting procedure for installation-specific permits after a comprehensive application is submitted. The baseline permit for the zone is issued by the Member State beforehand (as part of the zone designation process) and is not subject to this per-project timeline.

Related

This is general information about a draft EU regulation, not legal advice.